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Tag: privacy

  • Letter to Cineplex on Facial Detection

    In response to Cineplex Digital Media’s digital billboards performing facial detection, we submitted the following letter.

    See PDF version here.

    Thursday, December 4, 2025

    Dear Chief Privacy Officer at Cineplex Digital Media:

    We are writing to you with regards to privacy concerns surrounding your usage of Anonymous Video Analytics (AVA) in digital signage near Union Station Bus Terminal (USBT) and elsewhere in Canada. We represent both technologists and regular Canadians who see the value in innovation and technological development for public good.

    In 2020, the Office of the Privacy Commissioner of Canada (OPC), as well as the privacy commissioners for Alberta and British Columbia, released a report on a case involving use of AVA technology by Cadillac Fairview (CF) in 2018.1 The report found that CF’s AVA deployment constituted a violation of privacy, and that “express opt-in consent would be required, as they determined that some of the information involved was sensitive and its surreptitious collection in this context would be outside the reasonable expectations of consumers.”2

    We have a number of concerns relating to the aforementioned report and would like some clarifications.

    Concern 1: How has the joint investigation conducted in 2020 by the Offices of the Privacy Commissioner of Canada, Alberta and British Columbia affected CDM’s deployment of AVA technology? 

    Concern  2: A Toronto Star article by Kevin Jiang also mentions that CDM has consulted with the OPC for this project.3 How has this consultation mitigated some of the privacy issues that have arisen in the use of AVA?

    We also have concerns with certain statements in the privacy notice affixed to AVA-enabled digital signage by Cineplex (CDM).4

    Statement 1: This media unit runs anonymous software, used to generate statistics about audience counts, gender and approximate age only.

    Concern 3: What is the intended meaning of the phrase “anonymous software” per Statement 1 (also see Figure 1 in the Appendix)?

    Statement 2: Images are processed in a few milliseconds before being immediately and permanently deleted.

    Concern 4: If images are processed in the matter of milliseconds before being permanently deleted, this implies that images are only processed on-device, as opposed to being sent to a remote server or cloud service. Are images processed on-device?

    Concern 5: Is any personally identifying information or biometric data collected, inferred, extracted or stored beyond statistics on audience counts, gender and approximate age?

    Concern 6: Does the data collected by AVA reside in Canada?

    Concern 7: What measures are in place to protect data privacy during transfer and storage of data in remote servers or cloud facilities?

    We also have a number of concerns with certain statements in your notice of disclosure:5

    Statement 3: We ensure that the public is well informed as [sic] the presence of anonymous video analytics systems by placing signage and stickers on kiosks, at property entrance, exit ways and other places along the path to the property.

    Concern 8: Upon an investigation of Union Station Bus Terminal in early November 2025 by members of Technologists for Democracy, no warning of AVA systems was found except those attached to display signage themselves. This runs contrary to the above statement.

    Statement 4: Camera sensors are installed in plain sight and are never hidden. We want the public to understand exactly where they are placed so, if they chose, they can avoid it.

    Concern 9: Cameras attached to Cineplex’s digital signage are visible but quite small and difficult to identify. Over 90% of the general public interviewed by members of Technologists for Democracy were not previously aware of cameras attached to said signage. Areas where the digital ads are currently placed adjacent to USBT are unavoidable for individuals passing by in hallways coming from Union Station (i.e., two digital ads are placed very close to a train timetable, while the other is facing an entrance to USBT itself). This and concern 8 run contrary to the statements that cameras are “in plain sight”, “never hidden” and “if they [the public] chose, they can avoid it.”

    We also have a number of concerns with certain statements in your privacy policy:6

    Statement 5: Other Uses: We may also use Personal Information, where necessary, for:
    establishing, maintaining and/or fulfilling relationships with our business partners, third-party vendors of products and/or services, as well as our corporate and business customers;

    Concern 10: Are images of individuals sold to any third parties?

    Concern 11: Are statistics on audience counts, gender and approximate age sold to any third parties?

    Concern 12: Are any other data collected by AVA sold to third parties?

    Statement 6: Cineplex may also share Personal Information necessary to meet legal, audit, regulatory, insurance, security or other similar requirements. For instance, Cineplex may be compelled to disclose Personal Information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We may also share information with our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

    Concern 13: If data collected by AVA systems or digital signage is requested and sent to third parties for legally valid requests or enquiries, is there a mechanism for informing the public?

    Concern 14: If data collected by AVA systems or digital signage is requested and sent to third parties for legally valid requests or enquiries, is there a mechanism for third-party audits of such data requests or enquiries?

    Concern 15: It has been reported that CDM is being sold to US-based Creative Realities,7 who will take over ad billboards spanning malls and office buildings. Per this deal, will Creative Realities also take ownership of AVA systems? 

    We request that Cineplex Digital Media provide clarity on:

    1. How you are ensuring that individuals captured by AVA systems remain anonymous.
    2. How you are ensuring individuals are properly informed of recording and facial detection performed on premises.
    3. Your data policy and transparency around sharing of information to third parties.
    4. How your AVA system differs from Cadillac Fairview’s AVA system involved in the joint investigation conducted in 2020 by the Offices of the Privacy Commissioner of Canada, Alberta and British Columbia. 

    Innovation does not have to come at the cost of personal privacy. We are concerned with the lack of clarity surrounding the privacy notice and the privacy statements in CDM’s website. We are also alarmed at the prospect of a foreign company taking over CDM’s ad billboards to service software that may operate outside of Canadian laws and regulations.

    We would greatly appreciate a response within 10 business days. Please reply to this email or reach out directly to Khasir Hean at khasir.hean@gmail.com / 226-927-2677 if you have any questions or would like to discuss details further.

    Best,

    Adam Motaouakkil
    [email redacted for privacy] 

    Jitka Bartosova
    [email redacted for privacy] 

    Khasir Hean
    khasir.hean@gmail.com

    Technologists for Democracy
    techfordemocracy.ca 

    Signing organizations:

    Canadian Tech for Good
    Nikita Desai
    [email redacted for privacy] 

    More Transit Southern Ontario (MTSO)
    Jonathan Lee How Cheong
    [email redacted for privacy] 
    https://www.moretransit.ca/ 

    OpenMedia
    Matt Hatfield
    [email redacted for privacy] 
    https://openmedia.org/

    Tech Workers Coalition Canada
    Jenny Zhang
    [email redacted for privacy] 
    https://techworkerscoalition.org/canada/

    TTCriders
    Andrew Pulsifer
    [email redacted for privacy] 
    https://www.ttcriders.ca/

    Signing individuals:

    [names and emails of 25 individuals redacted for privacy]

    Appendix

    Privacy notice attached to digital signage by Cineplex Digital Media.
    Figure 1: Privacy notice attached to digital signage by Cineplex Digital Media.
    1. Joint investigation of the Cadillac Fairview Corporation Limited by the Privacy Commissioner of Canada, the Information and Privacy Commissioner of Alberta, and the Information and Privacy Commissioner for British Columbia. October 28, 2020. https://www.priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2020/pipeda-2020-004/ ↩︎
    2. Anonymous video analytics’ future uncertain after Canadian privacy regulators’ investigation. November 4, 2020. https://www.blg.com/en/insights/2020/11/anonymous-video-analytics-future-uncertain-after-canadian-priv acy-regulator-investigation ↩︎
    3. Jiang, Kevin. These ads near Union Station and other places around Toronto could be recording you. What you need to know. November 5, 2025. https://www.thestar.com/news/gta/these-ads-near-union-station-and-other-places-around-toronto-could-be-recording-you-what/article_7af7c920-1ce7-4b19-98db-4c22d742f202.html ↩︎
    4. See Appendix for the privacy notice in question (Figure 1). ↩︎
    5. Information on AVA | CDM. https://www.cdmexperiences.com/information-on-ava ↩︎
    6. Privacy Policy | CDM. Effective date April 10, 2024. https://www.cdmexperiences.com/privacy-policy ↩︎
    7. Deschamps, Tara. Cineplex selling digital signage unit to U.S. company Creative Realities for $70M. October 16, 2025. https://toronto.citynews.ca/2025/10/16/cineplex-digital-media-sale-signage/ ↩︎

  • Stop Cineplex from Facial Detection

    November 2025 — Now

    TL;DR: Cineplex Digital Media (CDM) makes digital billboards with cameras performing facial detection.

    Read our letter to Cineplex!
    One of the digital billboards that are performing facial detection at Union Station Bus Terminal.

    In early November, a Redditor discovered that ads at Union Station Bus Terminal have tiny cameras attached. The small privacy notice on the ads indicated that they run “anonymous software” to “generate statistics about audience counts, gender and approximate age”. Visiting their website tells us that they perform facial detection on anyone nearby!

    The privacy notice in question.

    CDM Cineplex Digital Media

    This media unit runs anonymous software, used to generate statistics about audience counts, gender and approximate age only.

    To ensure your privacy, no images and no data unique to an individual person is recorded by the camera in this unit. Images are processed in a few milliseconds before being immediately and permanently deleted.

    More information on the anonymous software and our Privacy Policy can be found at

    www.cdmexperiences.com/information-on-ava

    or scan the QR code below.

    News agencies quickly covered the issue, with articles coming out at Now Toronto, the Toronto Star, CTV News and Global News.

    Close up of the camera on top of the billboard.

    Volunteers at TfD have written an open letter to CDM. Organizations including OpenMedia, TTCriders and More Transit Southern Ontario have signed on, calling for CDM to answer our privacy concerns.

    Read the letter here!

  • Speed Cameras are an Effective Technology for Public Safety

    See PDF version here.

    FOR IMMEDIATE RELEASE

    Media contact: Khasir Hean – 226 927-2677 – khasir.hean@gmail.com

    September 25, 2025 (Toronto, ON) – Technologists for Democracy is a grassroots, volunteer-run advocacy organization. We are disappointed by Premier Ford’s decision to ban automated speed enforcement (ASE) cameras. The Hospital for Sick Children and Toronto Metropolitan University have found that ASE cameras in Toronto reduce the proportion of people speeding by 45%, and reduced motor vehicle speeds by 7km/h overall.1

    Reducing motor vehicle speeds is proven to improve safety. When the City of Toronto reduced speed limits from 40km/h to 30km/h, collisions decreased by 28%, and major and minor injuries decreased by 67%.2 Additionally, 73% of Ontarians support ASE cameras in targeted zones.3

    These facts point to the importance and popular support for enforcing speed limits and reducing motor vehicle speeds. We call on the Province of Ontario to commit to public safety by ensuring that drivers obey posted speed limits through ASE cameras to reduce collisions and injuries.

    Instead of spending taxpayer dollars on the removal of existing ASE camera infrastructure, we call on Premier Ford to cancel the upcoming ban on ASE cameras. The Province has not provided details of the provincial fund for spending taxpayer dollars on the removal of ASE camera infrastructure, nor on replacing ACE cameras with safe street infrastructure such as roundabouts or bike lanes. Pedestrian and bike-friendly infrastructure reduce incidences of collisions and speeding in areas where these interventions are applied.

    Separately, there are a number of privacy risks related to ASE cameras. We must ensure that privacy safeguards are built into ASE systems and policies so that data sharing and security best practices are followed, to maintain public trust. For instance, audio, visual and related data should be utilized only for speed monitoring, and not for other law enforcement purposes such as surveillance.  Similarly, license plate data collection and management should be constrained to speed monitoring and enforcement only, and should not be combined with other datasets for a different purpose. ASE cameras should not become multipurpose tools used for purposes other than for monitoring speed.

    We believe that a significant portion of the opposition to ASE cameras is caused by sub-par implementation. We also call on municipalities to improve implementation by focusing on the driver experience – for example, reducing the delay between incidence of speeding and ticket issuance, putting up signage and publishing open data on ASE camera locations, or providing clear feedback to drivers where speeding occurred. The public has a right to know where ASE cameras are, following transparency and open government principles.

    We at Technologists for Democracy believe that ASE cameras are an effective technology for maintaining public safety. In summary:

    • We call on the Province to take a stand for public safety by allowing for the implementation of ASE cameras.
    • We request that the data policies of ASE systems be designed with safeguards to use personal data minimally and protect public privacy.
    • We call on municipalities to improve ASE systems to focus on the driver experience and improve trust.
    1. The City of Toronto Automated Speed Enforcement Program Evaluation. March 28, 2023. https://www.toronto.ca/wp-content/uploads/2023/07/96cc-Automated-Speed-Enforcement-Program-Evaluation.pdf ↩︎
    2. Effect of reducing the posted speed limit to 30 km per hour on pedestrian motor vehicle collisions in Toronto, Canada – a quasi experimental, pre-post study. Fridman et al. February 10, 2020. https://bmcpublichealth.biomedcentral.com/articles/10.1186/s12889-019-8139-5 ↩︎
    3. CAA survey suggests 73% of Ontarians support speed cameras in targeted zones, even as cams cut down. Gabriela Silva Ponte. July 23, 2025. https://www.cbc.ca/news/canada/toronto/survey-finds-ontarianpurposes,s-support-speed-cameras-1.7592325 ↩︎

  • Platform Politics: Reflecting on Toronto’s History with Tech Giants

    What: A discussion of Toronto’s history with tech giants
    Location: University of Toronto, Sidney Smith Hall
    Date: September 4, 2025 from 5 – 7pm

    Register here!

  • Annex Gleaner, Aug 2025

    Volume 31, Number 3 (full text follows)

    Self-driving delivery vehicles spark privacy concerns

    Province approves Magna pilot for several wards including University-Rosedale

    By Abigail Harris

    Magna International, a global automotive supplier and mobility tech company, launched their Automated Vehicle Pilot Program in May 2025.

    The program is testing electric, self-driving delivery vehicles (SDVs) as part of a food delivery service, and the pilot area includes the Annex.

    The Ministry of Transportation Ontario (MTO) approved the pilot in April, allowing the vehicles to operate in Ward 9 and in portions of Wards 4, 5, 11, and 12.

    All vehicles will receive their own Ontario licence plates and will be subject to the same road rules as conventionally operated vehicles.

    According to Magna’s website, sensors on the vehicle will collect data from the surrounding area which will “incidentally include personal information such as images of people and vehicle license plates.”

    In June, Khasir Hean and Ilya Kreynin, members of the group Technologists for Democracy, wrote a letter to Magna along with four other members detailing their privacy concerns with the pilot.

    Kreynin and Hean joined other Technologists for Democracy members at city hall in June to discuss their concerns with the city’s infrastructure and environment committee, and city councillors passed a motion on June 26 to investigate data privacy issues surrounding Magna.

    Kreynin said that they became aware of the issue when fellow member JJ Fueser told them about the new self-driving vehicle pilot.

    “When JJ (Fueser) first brought this to our attention, and we gave a brief read of the open privacy policy that Magna has, it was egregiously overstepping,” Kreynin said. “We realized that there was really low awareness of this and that there wasn’t anybody else who was speaking out about this directly.”

    Hean said Magna is recording faces because they believe them to be useful in determining the gait of passersby in relation to their vehicles.

    “Magna fully intends to record the faces of individuals that it passes by on the streets because it believes that faces are useful to help predict where people are walking,” Hean said. “Other self-driving vehicle companies don’t record people’s faces. They blur them.”

    Magna states that they will retain this data for “as long as nec-essary,” which Kreynin says sets a dangerous precedent.

    “That’s entirely vague. They can keep it however long they want,” Kreynin said. “This is a new level of privacy breach in terms of this type of storing and anonymization. This company is running their cameras and robots into our neighborhood where people did not choose and consent to this happening.”

    The privacy policy also asserts that data will be shared with third parties such as insurance providers, law enforcement, and other officials when required by law.

    Hean says this raises many questions about Magna’s process of sharing this information and its ethicality.

    “Where’s the accountability in that?” Hean said. “How will we be informed if the police decide to use Magna as a live tracking device as well as a food delivery service? How do we and the public know this? There’s no mechanism to inform the public.”

    Kreynin says Magna responded to their letter in July, not by addressing their concerns, but by inviting them to tour their facility.

    [Image of a man picking up food from the Magna self-driving vehicle, with caption: Magna’s pilot program supports small-package deliveries like food, groceries, and retail items.]

    “While they invited us to the facility, they have not responded to any of the clear and direct concerns laid out in the letter in writing,” Kreynin said. “We have not received any kind of satisfactory or clear response from Magna at this time.”

    According to Kreynin, an important consideration in this emerging new technology is whether it is helping or hurting communities.

    “The point of the vehicles is to replace workers,” Kreynin said. “This industry is only set to expand in a way that is likely to hurt local businesses and communities. The question is, what is the effect that this has on our society? This pilot is not just a pilot [of] technology; it’s a pilot of integration into our society.”

    Magna International did not respond to the Gleaner’s request for an interview.

  • Stop Bill C-2 from Surveilling Us

    Bill C-2 was first introduced in May as an omnibus bill. It has faced criticism by multiple organizations:

    Many organizations have also criticized other aspects of the bill:

    There are a number of concerns that we as technologists have with regards to Bill C-2:

    1. Loss of privacy from requiring electronic service providers to provide basic subscriber information to CSIS and law enforcement agencies without a warrant.
      • Creation of a new term, electronic service provider, which includes social media platforms, email providers, messaging services, gaming platforms, internet service providers, and more…
    2. Reduction of oversight over CSIS and law enforcement agencies.

    Take action now to stop Bill C-2!

    Contact Your MP!

  • Tell Magna to Stop Recording our Faces

    June 2025 — October 2025

    Update 10/02/25: Magna is no longer operating its pilot in Toronto! Thank you to everyone for your support in making this happen. Innovation does not need to come at the cost of privacy!

    Our original post is below.

    On May 26, 2025, Magna International Inc. began a self-driving vehicle pilot for food delivery within the City of Toronto. Magna intends to blur license plates but record people’s faces within the vicinity of the vehicle because “Magna believes that faces are very useful to determine gaze, pose and intent of motion” according to a background report by the City.

    Other companies like Real Life Robotics, which is running a self-driving vehicle pilot in Markham, aren’t recording people’s faces: “the AI software [Real Life Robotics] use can easily scrub identifying features, like faces and licence plates.”

    How you can help!

    On June 27, we sent a letter (read here) to Magna with a list of specific privacy concerns based on their privacy policy.

    If you want to get involved with strategy and planning, sign up on our volunteer page!

    Get Involved!

    More info

    A view of Magna's delivery vehicle from the back. The vehicle is smaller than a car and has three wheels.
    Magna’s last-mile delivery device (LMDD) operating in Michigan.

    On June 11, 2025, the pilot was discussed at the City of Toronto’s Infrastructure and Environment committee. The pilot is under the jurisdiction of the Province of Ontario, but Toronto is allowed to submit comments and feedback to the Province.

    A map of the pilot area in Toronto.
    The pilot area in Toronto covers all of ward 9 and parts of wards 4, 5, 11 and 12.

    JJ, Ilya, Khasir and Akhil spoke up about the privacy concerns surrounding the pilot. Thanks to their voices, city councillors passed a motion on June 26 to investigate data privacy issues through the following questions:

    1. What type of data is being collected?
    2. Who has access to this data?
    3. Where is this data being stored?
    4. Can or will this data cross the border into the United States?
    5. Can Magna entities within the United States view the data?
    6. Would Magna entities be required to provide data to US or Canadian law enforcement if requested?
    7. Will facial recognition data be shared with law enforcement?
    8. Can future agreements change the nature of how the data is collected, stored, transmitted, and used?
    9. Are there any mechanisms for individuals, including those who cannot provide consent, such as children, to opt-out or request that their records be deleted?
    10. Are there ways to ensure that data can be destroyed if no consent was given?
    11. Can the terms and conditions of data management be changed, and if so, by whom?
    12. Does the City’s Digital Infrastructure Strategic Framework govern the collection and use of this data and if not, what can the City do when third parties want to harvest data in the public realm?